I. ASIA INTERNATIONAL AUCTIONEERS, INC v CIRGR NO. 179115, September 26, 2012FACTS:AIA is duly organized corporation operating within the Subic Special EconomicZone. It is engaged in the importation of used motor vehicles and heavy equipment which it sells to the public through auction. The former received a ormal letter of demand dated !uly "# $%%& from 'I( containing assessment for de)ciency value added ta* and e*cise ta* in the amounts of +,%$#-.-#-$%.%% and + ../,-.%%# respectively# or a total amount of + ,%0#1/%#$.-.%%# inclusive of penalties and interest# for auction sales conducted on ebruary -# 0# /# and 1# $%%&. +rompted AIAto )le a letter protest through registered mail on August .%# $%%& to 'I( but latter did not act on the protest. Thus# AIA )led petition for review before 'TA. 'TA )rst division ruled in favour of 'I(# granting its motion to dismiss the case. 'TA en 2anc a3rms the ruling of the 'TA )rst division.ISSUE:i. 4overnment Argument5 'I( argued that AIA is disquali)ed under Section 1 6a7 of (A "&1% from availing itself of the Ta* Amnesty +rogram because it is deemed a withholding agent for de)ciency ta*es.ii. Ta*payer Argrument5AIA contended that 2I( issued a 'erti)cation of 8uali)cationin favour to them# stating that 9it has availed and is quali)ed for Ta* amnesty for the Ta*able :ear $%%- and prior years pursuant to (A "&1%; otherwise s availment of the Ta* Amnesty +rogram under (A "&1% the outstanding de)ciency ta*es of it are deemed fully satis)edEL!::es.A ta* amnesty is a general pardon or the intentional overloo